Tax litigation solicitor

In July 2025, the Grand Chamber of the Supreme Court (Case No. 500/2276/24) put an end to a long-standing dispute over time limits. The rule is now as follows: if you have not lodged a complaint with the State Tax Service, you have six months from the date of receipt of the tax assessment notice to bring a claim before the court. If you did lodge a complaint and it was rejected, you have just one month after the conclusion of the administrative appeal. This is crucial, as dozens of websites and even some lawyers still refer to ‘1,095 days’. The Grand Chamber has made it clear: 1,095 days is the limitation period for the tax authority to assess taxes, not the time limit for bringing a claim before the court. Taxpayers who relied on this were refused leave to commence proceedings – not because of the substance of the dispute, but because of the time limit. A tax litigation solicitor is needed precisely at this stage: to calculate the time limit correctly, choose the appropriate route of appeal, and avoid losing the right to a defence due to a procedural error. +38 095 554-54-24 — legal advice

What we specialise in

• appeals against tax assessment notices (PPR) — additional assessments of VAT, corporation tax, personal income tax and penalties;
• unblocking tax invoices and removal from the list of high-risk taxpayers;
• support during tax audits — desk-based, documentary and on-site;
• appeals against audit orders and preventing unlawful audits;
• cancellation of tax debt, appeals against tax liens and seizure of property;
• disputes regarding VAT refunds from the state budget;
• defence in criminal proceedings under Article 212 of the Criminal Code (tax evasion).

Two ways to appeal a tax assessment notice — and why the choice is irreversible

Administrative appeal (complaint to the State Tax Service)

The complaint must be lodged with the higher-level supervisory authority within 10 working days of receiving the tax assessment notice (clause 56.3 of the Tax Code of Ukraine). The State Tax Service considers it within 20 calendar days; this period may be extended to 60 days. If a decision on the complaint is not issued in time, the complaint is deemed to have been upheld in favour of the taxpayer. Pros: free of charge; the financial liability remains unresolved, meaning no tax debt arises and assets are not frozen. Disadvantage: the State Tax Service rarely overturns decisions made by its own departments. And most importantly — once a claim has been rejected, you have only one month left.

Judicial appeal

Claim to the district administrative court. Time limit:

• 6 months from the date of receipt of the tax assessment notice — if you have not lodged a complaint with the State Tax Service;
• 1 month from the date of completion of the administrative appeal — if you have lodged one.

This fork in the road is the main pitfall. People lodge a complaint ‘just to have a go’, receive a rejection after two months, spend another month calmly preparing their claim — and then realise that the deadline has already passed. Therefore, the decision on whether to approach the State Tax Service must be made immediately upon receiving the tax assessment notice, not later.

What we check in every tax assessment notice

Most additional tax assessments are overturned not because of complex economic arguments, but due to procedural breaches by the tax authorities. We systematically check:

• the grounds for the audit — whether the order is lawful, whether the taxpayer was duly notified, and whether the grounds set out in Article 78 of the Tax Code of Ukraine have been met;
• time limits — whether the State Tax Service has exceeded the 1,095-day limitation period (Article 102 of the Tax Code);
• the content of the audit report — whether the conclusions are based on evidence, and whether there are references to specific source documents;
• the reality of business transactions — the most common ground for additional assessments (‘fictitious’ transactions with counterparties). Transport documents, stock records and business correspondence are relevant here;
• calculation of penalties — the State Tax Service’s arithmetic is wrong more often than is commonly thought;
• irregularities in the service of the tax assessment notice — the entire appeal period depends on the date of service.

Blocking of tax invoices

A separate category that businesses face constantly. The procedure:

1. Notification of the suspension of tax invoice registration — including a list of risk criteria.
2. Submission of explanations and documents to the regional commission. Here, the completeness of the package is decisive: contract, consignment note, payment orders, evidence of available resources.
3. Complaint to the State Tax Service — if the commission has refused. Time limit — 10 working days.
4. Court proceedings — if the refusal stands. At the same time, the decision to classify the taxpayer as high-risk must be challenged; otherwise, new tax invoices will continue to be blocked.

A key mistake businesses make is to challenge only the blocking of a specific tax invoice whilst leaving the high-risk taxpayer status unchallenged. The next one will be blocked.

When a solicitor is not needed

If the State Tax Service has identified a calculation error in your tax return and imposed a small additional charge, with which you agree, it is simpler to pay it. Going to court over an additional charge of 3,000 UAH makes no economic sense, and we will tell you so. You need a solicitor when:

• the amount of the additional charge is comparable to the costs of defence or greater;
• the State Tax Service has deemed your transactions to be fictitious — this affects not only the amount but also your reputation and business partners;
• you have been included on the list of high-risk taxpayers and your invoices are being blocked;
• the audit is taking place right now — the course of action is decided in the early stages, not after the audit report has been issued;
• there is a risk of criminal proceedings under Article 212 of the Criminal Code.

Time limits and court fees

Hearing of an administrative case: preparatory proceedings and hearing on the merits — as a general rule, up to 60 and up to 30 days respectively; in practice, the first instance in a tax dispute takes 6–12 months, and with an appeal and cassation, up to two years.  The minimum subsistence level for able-bodied persons in 2026 is 3,328 UAH. Court fees are calculated on the basis of this:

Submission via the ‘Electronic Court’ system entitles you to a 20% discount. If the case is won, court fees and lawyers’ fees are recovered from the State Tax Service.

How we work

1. Audit of the tax assessment notice and audit report — we look for procedural breaches, rather than simply disputing the amounts.
2. We calculate the time limits — and immediately determine whether it makes sense to go to the State Tax Service or to file a claim directly.
3. We prepare the evidence — source documents, proof of the reality of transactions, business correspondence.
4. We lodge a complaint or claim and represent you in courts at all levels.
5. We suspend enforcement — as long as the liability remains unresolved, no debt arises.
6. We support the audit process; if you engage us before it is completed, this is always cheaper than challenging the outcome afterwards.

Cost of services

The following are charged separately: court fees and, where necessary, a forensic economic assessment. Full price list Appeals against tax assessment notices Pre-litigation settlement of tax disputes

Questions and answers

How long do you have to appeal against a tax assessment notice?

10 working days to lodge a complaint with the State Tax Service. To take the matter to court: 6 months from the date of receipt of the tax assessment notice, if no complaint has been lodged, or 1 month after the conclusion of the administrative appeal. The 1,095-day period is the limitation period for the assessment of taxes, not for bringing a claim.

Is it worth lodging a complaint with the State Tax Service before going to court?

Not always. A complaint costs nothing and halts the accrual of tax debt, but if the claim is rejected, you are left with only one month. A decision must be made immediately, after weighing up the chances.

Does a tax debt arise whilst the appeal is ongoing?

No. As long as the liability has not been agreed – during the administrative appeal and from the date of applying to the court until the decision becomes final – no debt is accrued.

What should you do if a tax invoice has been blocked?

Submit an explanation and supporting documents to the commission; if your application is rejected, lodge a complaint with the State Tax Service within 10 working days, followed by legal action. At the same time, you must challenge the decision to classify you as a high-risk taxpayer; otherwise, the block will continue.

Can you prevent the tax authorities from carrying out an audit?

Yes, if the audit order was issued in breach of the rules or you were not properly notified. However, refusing access is a risky move: it may lead to the administrative seizure of your property. A decision is made only after analysing the audit order.

How long does a tax dispute last in court?

First instance – 6–12 months. Including appeal and cassation proceedings, it can take up to two years. It cannot be expedited, but whilst the dispute is ongoing, the debt is not enforced.

Can you recover legal fees from the State Tax Service?

Yes, if you win the case, the court will order the defendant to pay the legal costs, including the costs of professional legal assistance. The court assesses the amount on the basis of reasonableness, so it is important to draw up the reports and calculations correctly.

What documents should I bring to the consultation?

The tax assessment notice, the audit report, the audit order, any objections (if submitted), the State Tax Service’s decision on the complaint (if applicable), and the source documents relating to the disputed transactions.

Contact a tax dispute solicitor at Svarog

Send us the tax assessment notice and the audit report — we will check the time limits, identify any procedural breaches and advise you on which appeal route offers the best chance of success in your specific situation. If there is no prospect of success, we’ll tell you straight away, before you pay the court fees. +38 095 554-54-24 · Kyiv, 7 Khoriva Street, Office 2 (Podil) · Mon–Fri 9.00–18.00